Richard Syratt is a Managing Director with Alvarez & Marsal Taxand in London, with more than 20 years of corporate and international tax and transfer pricing experience. He focuses on international tax structuring.

He spent more than 19 years with Deloitte, serving the latter six as a Partner.

Dr. Syratt’s clients include a number of the U.K.’s top-listed multinationals, with projects ranging from “boxes-and-lines” planning such as large debt restructuring projects, tax efficient financing, acquisition structures, mergers, demergers and JV structuring, to substance-based business changes, including intellectual property centralization, structuring into tonnage tax and implementing franchise arrangements.

Prior to joining A&M, Dr. Syratt managed a number of large compliance engagements throughout his career, from corporate tax return preparation and global transfer pricing documentation to handling various tax authority audits and investigations, delivering APAs and making competent authority claims.

His transactional experience includes private-equity and corporate deals, including tax work for several IPOs – designing and implementing the post-float structure, and long-form, short-form and working capital reports.

He led the tax input into one of Europe’s largest debt restructurings, gaining detailed experience with the U.K. loan relationship rules, preserving tax losses and minimizing tax cash leakage.

Dr. Syratt earned a bachelor’s degree in physics and a doctorate degree in applied optics from Imperial College. He is a qualified chartered accountant and member of the ICAEW.

This week Majesty’s Revenue & Customs (HMRC), the U.K.’s tax authority, released key statistics related to the U.K. Diverted Profits Tax (DPT)[1] . DPT of £138m has been collected during the period from April 2015 (when the tax was introduced) to April 2017. Diageo announced in May this year that it would be paying £107m, but intends to challenge the assessment, so it is possible some of the amounts collected will be refunded. HMRC also estimates it collected £174m of additional corporation tax from behavioral changes – this figure will be a low estimate and will only accurately capture situations already under HMRC enquiry.

The main change of CbCR requirements that will impact the reporting and compliance burden on U.K. companies relates to the additional notification requirement. This change is in line with the OECD Model and the EU Directive on Administrative Cooperation (2011/16/ EU, or DAC4) on mandatory exchange of information. It will possibly not be welcomed by companies as it creates an additional deadline outside the annual selfassessment return process, even though the actual notification will probably be identical for later years for most companies.

The U.K. has introduced new anti-hybrid rules that are effective from 1 January 2017. These represent the U.K.’s implementation of the recommendations arising from Action 2 of the Organisation for Economic Co-operation and Developments (“OECD”) Base Erosion and Profit Shifting (“BEPS”) project.

Across the pond, the recent inauguration of Donald Trump as the U.S.’s 45th president combined with Republicans maintaining control of both the House of Representatives and the Senate presents the possibility of perhaps the most significant U.S. tax reform since the Reagan Tax Reform Act of 1986.

Last year, many early-stage companies significantly reduced payroll taxes thanks to a new federal tax credit including many of our start-ups in the tech industry. The Qualified Small Business (QSB) R&D Tax Credit, passed into law in 2015, allows qualified small businesses to offset OASDI (i.e. social security) taxes with R&D tax credits originally claimed on federal income tax returns. The 2018 calendar year presents yet another opportunity for companies to realize these savings. How are these credits achieved?